`
`
`
`MIT’s/EBS’s Preliminary Infringement Chart (Ex. A – U.S. Patent No. 8,069,839)
`MIT/EBS v. Ford, No. 19-cv-196 (D. Del. 2019)
`
`Exhibit A
`
`U.S. Patent No. 8,069,839 (Issued Dec. 6, 2011)
`
`The following claim charts include illustrations, photographs, and references relating to Ford Engines using the Ford “port-fuel and direct injection [PFDI] system,” including, but not limited to, the 1.5L “Dragon”
`EcoBoost Engine; Second Generation 2.7L and 3.5L EcoBoost Engines; 3.5L High Output Second Generation EcoBoost Engine; and the 3.3 Ti-VCT V6 and 5.0 Ti-VCT V8 Engines (collectively, the “Accused Products,”
`“Accused Instrumentalities,” or “Accused Engines”). The preliminary infringement contentions set forth in these charts apply to each model of Accused Products, including those identified elsewhere in Plaintiffs’ First
`Disclosure of Asserted Claims and Infringement Contentions, as well as all models and revisions identified by Defendants. Further, unless expressly stated otherwise, the evidence of infringement identified herein should be
`understood as a non-limiting example of how Plaintiffs allege that all accused products set forth for that claim—or the claim(s) on which that claim depends—infringe.
`
`’839 Patent Claim
`Element
`1[a]. A spark
`ignition engine that
`is fueled both by
`direct injection and
`by port injection
`
`
`Preliminary Infringement Theory
`
`The Accused Products include a spark ignition engine that is fueled both by direct injection and by port injection.
`
`The Accused Products include turbocharged and/or naturally aspirated spark-ignition engines (e.g., Exs. 1-5, 10) that include a fuel management system that utilizes both port fuel injection (PFI) and
`direct fuel injection (DI), which Ford refers to as, among other things, the “Ford port-fuel and direct-injection (PFDI) system.” See, e.g., Ex. 1 [EBS-00002931, at 937] (“The ultimate strategy is
`combining both PI and DI benefits, using each to diminish the other’s negatives.”); id. [EBS-00002931, at 935] (“Ford currently is the dominant player with what it calls dual-fuel, high-pressure direct
`injection (DI) and lower-pressure port injection (PI). Applications include turbocharged and naturally aspirated V-6 and V-8 gasoline engines—four in all—ranging in size from 2.7 to 5.0 liters…. Step
`one [of such DI system] is atomizing the liquid to fine droplets, achieved by forcing gasoline pressurized by a pump through tiny injector orifices.”); Ex. 4 [EBS-00002951, at 953] (“The redesigned V-
`6 [has] two fuel injection systems: direct injection and port fuel injection.”); Ex. 10 [EBS-00003074, at 076] (“The 3.5L EcoBoost . . . engine delivers the F-150 best-in-class tow rating . . . . Features
`include the Ford port-fuel and direct-injection (PFDI) system with two injectors per cylinder — one in the air intake port, another inside the cylinder — to increase performance. Plus twin intercooled
`turbos for on-demand power with virtually no lag.”); Ex. 15 [EBS-00003169, at 171] (“Power for the 2018 Lincoln Navigator comes from a second-generation twin-turbo 3.5-liter EcoBoost V6 . . . .”);
`Ex. 4 [EBS-00003074, at 077] (“Under the unique Raptor hood is the 24-valve, 3.5L twin-turbo HO EcoBoost with Ford port-fuel and direct injection (PFDI) system . . . .”); id. [EBS-00003074, at 078]
`(“The 3.3L Ti-VCT V6 delivers responsive performance with 290 horsepower and 265 lb.-ft. of torque. The twin independent variable cam timing (Ti-VCT) opens/closes the valves in precise duration
`to suit operating conditions, so power output is optimized at every point across the performance band. The 3.3L also has the Ford port-fuel and direct-injection (PFDI) system with two injectors per
`cylinder — one mounted in the air intake port, another inside the cylinder.”); id. [EBS-00003074, at 078] (disclosing that Ford’s “5.0L TI-VCT V8” engine utilizes “the Ford port-fuel and direct-
`injection (PFDI) system with two injectors per cylinder — one in the air intake port, another inside the cylinder — to increase power and efficiency.”); Ex. 11 [EBS-00003085, at 086] (“The naturally
`aspirated 5.0-Liter Coyote V8 in the 2018 Ford Mustang . . . now combines low-pressure port and high-pressure direct injection, has two new anti-knock sensors, redesigned cylinder heads and new
`crankshaft and connecting rod bearings.”); Ex. 3 [EBS-00002946, at 948] (“With advanced dual port and direct-injection technology, the all-new second-generation 2.7-liter EcoBoost engine delivers a
`25 lb.-ft. increase in torque, and at lower engine speeds compared to a traditional V8. Like the second-generation 3.5-liter EcoBoost that debuted last model year, the 2.7-liter will be paired to a
`segment-exclusive 10-speed automatic transmission for 2018.”); Ex. 10 [EBS-00003074, at 075] (“How can an engine displacing just 2.7 liters deliver a robust 325 horsepower and 400 lb.-ft of torque?
`Engineer it with the Ford port-fuel and direct-injection (PFDI) system with two injectors per cylinder . . . .”); Ex. 5 [EBS-2955, at 957] (“A new combination of port fuel injection and direct fuel
`injection technology [for the 1.5L Dragon EcoBoost] helps deliver high power and responsiveness alongside reduced CO2 emissions,* with a particular increase in fuel efficiency under light engine
`loads.”).
`Above a selected torque value the ratio of fuel that is directly injected to fuel that is port injected increases.
`
`The Accused Products include a fuel management system, which Ford identifies as, among other things, the “Ford port-fuel and direct injection (PFDI) system,” that utilizes both port fuel injection
`(PFI) and direct fuel injection (DI). E.g., Ex. 10 [EBS-00003074, at 075]; see also, e.g., Exs. 1-5. As noted above, in such engines, fuel delivery occurs via “PI alone at idle and at low rpm,” but “[a]s
`rpm and load increase, fuel delivery becomes a programmed blend of PI and DI.” Ex. 1 [EBS-00002931, at 938].
`
`Further, laboratory testing performed by the National Highway Traffic Safety Administration confirmed the following: “The PFI system provides the fuel to the engine when the absolute engine load is
`below 40 percent. The DI system is quickly blended in above 40 percent absolute engine load. Between 60 percent to 140 percent absolute load, 80 percent to 70 percent of the fuel is delivered through
`the DI system. At absolute engine loads above 140 percent the PFI system provides an increase proportion of the fuel up to 40 percent. At the maximum absolute load above 2,000 rpm 60 percent of the
`fuel is provided by the DI system and 40 percent by the PFI system that corresponds to the values shown in the maximum acceleration test in Figure 24.” Ex. 9 [EBS-00002974, at 026].
`
`[1b] wherein above
`a selected torque
`value the ratio of
`fuel that is directly
`injected to fuel that
`is port injected
`increases;
`
`
`
`
`
`
`1
`
`FORD Ex. 1136, page 1
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`
`

`

`MIT/EBS’s Preliminary Infringement Chart (Ex. A – U.S. Patent No. 8,069,839)
`MIT/EBS v. Ford, No. 19-cv-196 (D. Del. 2019)
`
`
`Preliminary Infringement Theory
`
`’839 Patent Claim
`Element
`
`Ex. 9 [EBS-00002974, at 026].
`
`Further, it has been reported that Ford’s use of PFI “allows engineers to shut down the direct-injection system and its mechanical pump at low speeds and under low loads, reducing friction losses and
`emissions.” Ex. 16 [EBS-00003177, at 180]. And it has been reported that the ratio of directly injected fuel to port injected fuel can eventually increase under such heightened load/torque values such
`that only “5 to 10 percent of the fuel delivery” is provided via port injection. Ex. 1 [EBS-00002931, at 938].
`The engine may be operated at a substantially stoichiometric fuel/air ratio.
`
`
`
`
`[1c] and wherein
`the engine is
`operated at a
`
`
`
`
`
`2
`
`FORD Ex. 1136, page 2
` IPR2020-00013
`
`

`

`MIT/EBS’s Preliminary Infringement Chart (Ex. A – U.S. Patent No. 8,069,839)
`MIT/EBS v. Ford, No. 19-cv-196 (D. Del. 2019)
`
`
`Preliminary Infringement Theory
`
`As noted above, the Accused Instrumentalities include a fuel management system, which Ford identifies as, among other things, the “Ford port-fuel and direct injection (PFDI) system,” that utilizes
`both port fuel injection (PFI) and direct fuel injection (DI). Ex. 10 [EBS-00003074, at 075]; see also, e.g., Exs. 1-5.
`
`Ford vehicles equipped with the Accused Instrumentalities utilize what are known in the industry as “three way” catalytic converters, which are understood in the industry to ensure that an engine is
`operating at a stoichiometric fuel/air ratio. See, e.g., Ex. 8 [EBS-00002969, at 971] (“In practice, three-way catalytic converters are used with air to fuel ratio controllers which maintain the mixture
`composition at stoichiometric.”); see also, e.g., Ex. 12 [EBS-00003091, at 123] (providing warranty coverage for the catalytic converters present in every Ford vehicle).
`
`As shown below, the laboratory testing performed by the National Highway Traffic Safety Administration confirms that, for example, Ford’s 3.5L Second Generation EcoBoost engine is operated at a
`substantially stoichiometric fuel/air ratio, where Lambda ≅ 1.
`
`’839 Patent Claim
`Element
`substantially
`stoichiometric
`fuel/air ratio.
`
`
`
`
`Ex. 9 [EBS-00002974, at 018].
`2. The spark
`See Claim 1.
`ignition engine of
`
`claim 1 where the
`The ratio of directly injected fuel to port injected fuel increases with increasing torque.
`ratio of directly
`
`injected fuel to port
`The Accused Instrumentalities include a fuel management system, which Ford identifies as, among other things, the “Ford port-fuel and direct injection (PFDI) system,” that utilizes both port fuel
`injected fuel
`injection (PFI) and direct fuel injection (DI). Ex. 10 [EBS-00003074, at 075]; see also Exs. 1–5. As also noted above, in such engines, fuel delivery occurs via “PI alone at idle and at low rpm,” but
`increases with
`that, “[a]s rpm and load increase, fuel delivery becomes a programmed blend of PI and DI.” Ex. 1 [EBS-00002931, at 938].
`increasing torque.
`
`Laboratory testing performed by the National Highway Traffic Safety Administration confirmed the following: “The PFI system provides the fuel to the engine when the absolute engine load is below
`40 percent. The DI system is quickly blended in above 40 percent absolute engine load. Between 60 percent to 140 percent absolute load, 80 percent to 70 percent of the fuel is delivered through the DI
`system.” Ex. 9 [EBS-00002974, at 026].
`
`
`
`
`
`
`
`3
`
`FORD Ex. 1136, page 3
` IPR2020-00013
`
`

`

`’839 Patent Claim
`Element
`
`3. The spark
`ignition engine of
`claim 2 where the
`ratio of directly
`injected fuel to port
`injected fuel is
`determined by a
`signal from a knock
`detector.
`
`MIT/EBS’s Preliminary Infringement Chart (Ex. A – U.S. Patent No. 8,069,839)
`MIT/EBS v. Ford, No. 19-cv-196 (D. Del. 2019)
`
`
`Preliminary Infringement Theory
`
`
`It has been reported that Ford’s use of PFI “allows engineers to shut down the direct-injection system and its mechanical pump at low speeds and under low loads, reducing friction losses and
`emissions.” Ex. 16 [EBS-00003177, at 180].
`
`It also has been reported that the ratio of directly injected fuel to port injected fuel can eventually increase under such heightened load/ torque values such that only “5 to 10 percent of the fuel delivery”
`is provided via port injection. Ex. 1 [EBS-00002931, at 938].
`The ratio of directly injected fuel to port injected fuel is determined by a signal from a knock detector.
`
`See Claim 2.
`
`For example, Ford utilizes sensor(s) that detect knock. See, e.g., Ex. 6 [EBS-00002962, at 963] (“The Ford Ecoboost knock detection system is one of the more complex systems out there. . . . It actually
`learns your fuel quality while you drive. All the EB engines we work with use this adaptive timing system. .… The knock detection system starts with the sensors (microphones) that pick up engine
`noise and are mounted to the engine block. If the engine noise falls within the correct frequency and window of operation (around the time the spark plug fires), the ECU registers this as knock.” (emphasis
`added)); Ex. 11 [EBS-00003085, at 87] (“The naturally aspirated 5.0-Liter Coyote V8 in the 2018 Ford Mustang may seem like an already familiar engine, but Ford has improved on it for the current
`model year. The cylinders have been bored out to 93.0 mm, up from 92.2 mm. The V8 now combines low-pressure port and high-pressure direct injection, has two new anti-knock sensors . . . and it’s
`more powerful than before, providing up to a peak 460 horsepower and 420 pounds-feet of torque, up from the previous 435 hp and 400 lb-ft. That extra powers comes without sacrificing fuel economy.”).
`
`Knock is a significant issue at moderate-to-high loads (also known as torques). In general, knock is what limits how much torque a gasoline engine can make at lower engine speeds (where the engine is
`used most of the time). As a result, the engine can create more low-speed torque through methods than mitigate knock. See, e.g., Exs. 1 [EBS-00002931, at 936] (“With DI, the chance of detonation—
`premature ignition of the fuel and air mixture—is diminished because the phase-change cooling effect takes place during the compression stroke just before ignition. Lowering the combustion chamber’s
`surface temperatures enables a higher compression ratio and improved efficiency whether the engine is naturally aspirated or boosted. Ford raised peak torque by 30 lb-ft in its new 3.5-liter V-6 by
`combining the new dual-injection strategy with higher boost pressure.”); Ex. 3 [EBS-00002946, at 948] (“With advanced dual port and direct-injection technology, the all-new second-generation 2.7-liter
`EcoBoost engine delivers a 25 lb.-ft. increase in torque, and at lower engine speeds compared to a traditional V8.”). Direct injection mitigates knock in Ford engines by cooling the in-cylinder charge.
`See, e.g., Ex. 1 [EBS-00002931, at 36] (“With DI, the chance of detonation—premature ignition of the fuel and air mixture—is diminished because the phase-change cooling effect takes place during the
`compression stroke just before ignition. Lowering the combustion chambers’ surface temperatures enables a higher compression ratio and improved efficiency whether the engine is naturally aspirated
`or boosted. Ford raised peak torque by 30 lb-ft in its new 3.5-liter V-6 by combining the new dual-injection strategy with higher boost pressure.”); Ex. 7 [EBS-00002968, at 968] (“Pete Dowding, Ford
`Powertrain’s well-travelled chief engineer, told Automotive Engineering the cost of moving all the F-150’s engines to the direct- and indirect-injection layout is justified by the increased fuel economy
`the designs permit—largely because of the higher compression ratios (CR) available from overlaying PFI onto DI. At high load, DI cools the cylinder sufficiently to maintain a high CR without high-
`octane unleaded. At lower loads, “the DI system bleeds off,” Dowding said, and PFI takes priority, delivering efficient cylinder-fill while still reaping the BMEP benefit of higher compression.”).
`
`Thus, it can be inferred that the ratio of directly injected fuel to port injected fuel is determined by a signal from a knock detector. See, e.g., Ex. 1 [EBS-00002931, at 938] (“Ford uses PI alone at idle
`and at low rpm for smooth, quiet, and efficient engine operation. As rpm and load increase, fuel delivery becomes a programmed blend of PI and DI.). When knock is registered, the ECU looks at the
`Knock Response table pictured below. Based on the intensity of the knock, the fuel management system subtracts timing from the Ign. Corr. Cyl X Parameter … on a per cylinder basis” such that,
`“[t]he more intense the knock, the more timing will be pulled.” Ex. 6 [EBS-00002962, at 963]. “The beauty behind this knock control system that both adds and subtracts timing is that it also LEARNS
`the quality of your fuel over time. The learning variable is called OAR (Octane Adjust Ratio).” Id. [EBS-00002962, at 964]. “Keep in mind that these knock detection systems are extremely fast to
`react. If knock is detected, if setup correctly, the system will very quickly pull timing to stop the knocking during that pull and adjust the tune for future pulls.” Id [EBS-00002962, at 965].
`
`
`
`
`
`4
`
`FORD Ex. 1136, page 4
` IPR2020-00013
`
`

`

`MIT/EBS’s Preliminary Infringement Chart (Ex. A – U.S. Patent No. 8,069,839)
`MIT/EBS v. Ford, No. 19-cv-196 (D. Del. 2019)
`
`
`Preliminary Infringement Theory
`
`’839 Patent Claim
`Element
`
`Ex. 6 [EBS-00002962, at 963].
`
`
`
`
`
`
`
`5
`
`FORD Ex. 1136, page 5
` IPR2020-00013
`
`

`

`MIT/EBS’s Preliminary Infringement Chart (Ex. A – U.S. Patent No. 8,069,839)
`MIT/EBS v. Ford, No. 19-cv-196 (D. Del. 2019)
`
`
`Preliminary Infringement Theory
`
`’839 Patent Claim
`Element
`
`Ex. 9 [EBS-00002974, at 026].
`4. The spark
`See Claim 3.
`ignition engine of
`
`claim 3 further
`The spark ignition engine includes a microprocessor that controls the ratio of the directly injected fuel to the port injected fuel based on the signal from the knock detector. For example, in EcoBoost
`including a
`engines, the “ECU signal . . . define[s] the ratio of fuel flow between the PFI and DI system.” Ex. 9 [EBS-00002969, at 003]. “The knock detection system starts with the sensors (microphones) that
`microprocessor that
`pick up engine noise and are mounted to the engine block. If the engine noise falls within the correct frequency and window of operation (around the time the spark plug fires), the ECU registers this
`as knock.” Ex. 6 [EBS-00002962, at 963]. “When knock is registered, the ECU looks at the Knock Response table” to “subtract timing advance from the Ign. Corr. Cyl X Parameter” or
`controls the ratio of
`“increment[] the Knock Count Cyl X parameter which can also be viewed.” Id [EBS-00002962, at 963].
`the directly injected
`fuel to the port
`
`injected fuel based
`The ECU likely controls the ratio of the directly injected fuel to the port injected fuel based such signals. See Claim 3.
`
`
`
`
`
`
`
`6
`
`FORD Ex. 1136, page 6
` IPR2020-00013
`
`

`

`MIT/EBS’s Preliminary Infringement Chart (Ex. A – U.S. Patent No. 8,069,839)
`MIT/EBS v. Ford, No. 19-cv-196 (D. Del. 2019)
`
`
`Preliminary Infringement Theory
`
`See Claim 2.
`
`Open loop control is used to determine the ratio of the directly injected fuel to the port injected fuel. For example, it has been reported that, given a certain rpm/engine load range and/or torque value, it
`will be determined whether the engine is fueled solely by port fuel injection, or by a combination of port fuel injection and direct injection. See, e.g., Ex. 1 [EBS-00002931, at 938] (“Ford uses PI alone
`at idle and at low rpm for smooth, quiet, and efficient engine operation. As rpm and load increase, fuel delivery becomes a programmed blend of PI and DI.”); Ex. 4 [EBS-00002951, at 953] (“The
`redesigned V-6 [has] two fuel injection systems: direct injection and port fuel injection. The engine ... runs on port injection when cold and under low-load situations and switches to direct injection
`when warm or when extra power is needed ....”).
`
`’839 Patent Claim
`Element
`on the signal from
`the knock detector.
`
`5. The spark
`ignition engine of
`claim 2 where open
`loop control is used
`to determine the
`ratio of the directly
`injected fuel to the
`port injected fuel.
`
`
`
`
`
`7
`
`FORD Ex. 1136, page 7
` IPR2020-00013
`
`

`

`MIT/EBS’s Preliminary Infringement Chart (Ex. A – U.S. Patent No. 8,069,839)
`MIT/EBS v. Ford, No. 19-cv-196 (D. Del. 2019)
`
`
`Preliminary Infringement Theory
`
`’839 Patent Claim
`Element
`
`Ex. 9 [EBS-00002974, at 3026].
`See Claim 1.
`
`The engine operates at a substantially stoichiometric fuel/air ratio at the highest loads.
`
`
`
`
`8
`
`6. The spark
`ignition engine of
`claim 1 where the
`engine operates at a
`substantially
`
`
`
`
`
`FORD Ex. 1136, page 8
` IPR2020-00013
`
`

`

`’839 Patent Claim
`Element
`stoichiometric
`fuel/air ratio at the
`highest loads.
`
`MIT/EBS’s Preliminary Infringement Chart (Ex. A – U.S. Patent No. 8,069,839)
`MIT/EBS v. Ford, No. 19-cv-196 (D. Del. 2019)
`
`
`Preliminary Infringement Theory
`
`For example, Ford vehicles equipped with the Accused Instrumentalities utilize what are known in the industry as “three way” catalytic converters, which are understood in the industry to ensure that
`an engine is operating at a stoichiometric fuel/air ratio. See, e.g., Ex. 8 [EBS-00002969, at 971] (“In practice, three-way catalytic converters are used with air to fuel ratio controllers which maintain the
`mixture composition at stoichiometric.”); see also, e.g., Ex. 12 [EBS-00003091, at 123] (providing warranty coverage for the catalytic converters present in every Ford vehicle).
`
`Further, and as indicated below, the laboratory testing performed by the National Highway Traffic Safety Administration shows that Ford’s 3.5L Second Generation EcoBoost engine is operated at a
`substantially stoichiometric fuel/air ratio at the engine’s highest loads. See, e.g., Ex. 9 [EBS-00002974].
`
`Ex. 9 [EBS-00002974, at 006].
`7. The spark
`See Claim 1.
`ignition engine of
`
`claim 1 where the
`The engine operates at some value of torque with port fuel injection alone.
`engine operates at
`
`some value of
`For example, it has been reported that Ford’s use of PFI “allows engineers to shut down the direct-injection system and its mechanical pump at low speeds and under low loads, reducing friction losses
`torque with port
`and emissions.” Ex. 16 [EBS-00003177, at 180].
`fuel injection alone.
`
`
`
`
`
`
`
`
`9
`
`FORD Ex. 1136, page 9
` IPR2020-00013
`
`

`

`’839 Patent Claim
`Element
`
`8. The spark
`ignition engine of
`claim 1 where the
`engine operates at
`some value of
`torque with direct
`injection alone.
`
`
`MIT/EBS’s Preliminary Infringement Chart (Ex. A – U.S. Patent No. 8,069,839)
`MIT/EBS v. Ford, No. 19-cv-196 (D. Del. 2019)
`
`
`Preliminary Infringement Theory
`
`Further, it has been reported that, at certain rpm/engine load ranges (i.e., torque values), such engines are fueled entirely via port fuel injection. See, e.g., Ex. 1 [EBS-00002931, at 938] (“Ford uses PI
`alone at idle and at low rpm for smooth, quiet, and efficient engine operation.” (emphasis added)); Ex. 4 [EBS-00002951, at 953] (“The redesigned V-6 [has] two fuel injection systems: direct injection
`and port fuel injection. The engine ... runs on port injection when cold and under low-load situations and switches to direct injection when warm or when extra power is needed ....”).
`
`In addition, laboratory testing performed by the National Highway Traffic Safety Administration confirmed the following: “The PFI system provides the fuel to the engine when the absolute engine
`load is below 40 percent.” Ex. 9 [EBS-00002974, at 026].
`See Claim 1.
`
`The engine operates at some value of torque with direct injection alone.
`
`For example, laboratory testing performed by the National Highway Traffic Safety Administration confirmed that the engine operates at some value of toque with direct injection alone. For example,
`“[w]hen the vehicle comes to a complete stop the engine idles at 575 rpm for 1.3 to 1.5 seconds during which time the injection system transitions from PFI to DI before the engine is stopped.
`After the engine is stopped, the high pressure fuel pump and a fuel volume control valve accumulate approximately 2.3 ml of fuel. The low pressure fuel pump in the tank increases its duty cycle while
`the engine is stopped. When the driver stops pressing the brake pedal, the engine is restarted. The stored high pressure fuel volume is fed through the DI system to restart the engine.” Ex. 9 [EBS-
`00002974, at 024] (emphasis added). Further, the same laboratory testing confirmed that in such circumstances the engine operates at “100 percent DI” at “575 rpm and 40 percent absolute load.”
`Ex. 9 [EBS-00002974, at 026] (emphasis added).
`
`
`
`
`
`10
`
`FORD Ex. 1136, page 10
` IPR2020-00013
`
`

`

`MIT/EBS’s Preliminary Infringement Chart (Ex. A – U.S. Patent No. 8,069,839)
`MIT/EBS v. Ford, No. 19-cv-196 (D. Del. 2019)
`
`
`Preliminary Infringement Theory
`
`’839 Patent Claim
`Element
`
`Ex. 9 [EBS-00002974, at 026].
`
`
`
`
`
`
`
`
`
`11
`
`FORD Ex. 1136, page 11
` IPR2020-00013
`
`